McDermott International, Inc. v. Wilander

Background

Jon Wilander was a paint foreman employed by McDermott who worked aboard the American-flag paint boat MW Gates Tide while servicing oil platforms. He was struck in the head by a blown bolt on July 4, 1983, and sued his employer under the Jones Act, a federal law that allows seamen to sue for employer negligence. A jury found he spent substantial time aboard the Gates Tide, that his duties contributed to the vessel’s function, and awarded damages; the Fifth Circuit affirmed his seaman status under the Robison test. The Court granted review to resolve conflicting tests used by lower courts.

Reasoning

The Court addressed whether a worker must aid in navigation or transportation to be a seaman. Tracing maritime law, it concluded the Jones Act did not adopt a narrow navigation-only rule. Instead, seaman status depends on an employee’s connection to a vessel in navigation and whether the worker performs the ship’s work that furthers the vessel’s function or mission. The Court rejected a strict requirement that a seaman aid in navigation or transport, approved the Robison formulation, and explained seaman status is a mixed question of law and fact for courts and juries to apply.

Real world impact

Because Wilander’s shipboard painting work contributed to the Gates Tide’s mission, the Court affirmed that he is a seaman under the Jones Act even though he did not navigate the boat. The ruling resolves the split over the navigation requirement and instructs lower courts to assess seaman status by the worker’s connection to the vessel and performance of its work. Cases will remain fact-specific and may go to juries when reasonable people could disagree.